California voters will face 11 statewide ballot initiatives when they visit the polls in less than three weeks.  One, Proposition 32, has garnered significant media attention because it would bar unions from using payroll deduction to collect PAC contributions.  Its effects on corporate PACs — which could be just as far-reaching — have been largely ignored. 

Although the union payroll deduction prohibition has drawn the ire of the state’s unions, that same provision also prevents corporations from “deduct[ing] from an employee’s wages, earnings, or compensation any amount of money to be used for political purposes.”  If the deducted funds go to the corporation’s federal PAC and the PAC then uses them to make contributions to California candidates or parties, they are used for “political purposes.”  What does this mean for federal PACs?  If Proposition 32 is passed, many of those PACs may have to stay out of California state races.  Many federal corporate PACs (especially those affiliated with big companies) raise their funds by asking their executives to automatically enroll in a payroll deduction plan pursuant to which a specific amount is automatically deducted from the executive’s paycheck.  If the initiative passes, it appears that those PACs would be prohibited from using that money to contribute to California state candidates or state political parties.

So what will corporations with federal PACs active in California do if Proposition 32 becomes law?  Establish separate California PACs that do not raise funds through payroll deduction?  Annually ask employees to make automated payments through their credit cards rather than via payroll deduction?  Give up payroll deduction entirely?  One option that will be off the table: making direct corporate contributions to candidates and parties.  Proposition 32 also bars those.

Photo of Zachary G. Parks Zachary G. Parks

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside…

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside attorney for election law, campaign finance, pay-to-play and PAC issues.” Zachary is also a leading lawyer in the emerging corporate political disclosure field, regularly advising corporations on these issues.

Zachary’s expertise includes the Federal Election Campaign Act, the Lobbying Disclosure Act, the Ethics in Government Act, the Foreign Agents Registration Act, and the Securities and Exchange Commission’s pay-to-play rules. He has also helped clients comply with the election and political laws of all 50 states. Zachary also frequently leads political law due diligence for investment firms and corporations during mergers and acquisitions.

He routinely advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended his political law clients in investigations by the Federal Election Commission, the U.S. Department of Justice, Congressional committees, and in litigation.

Zachary is also the founder and chair of the J. Reuben Clark Law Society’s Political and Election Law Section.

Zachary also has extensive complex litigation experience, having litigated major environmental claims, class actions, and multi-district proceedings for financial institutions, corporations, and public entities.

From 2005 to 2006, Zachary was a law clerk for Judge Thomas B. Griffith on the United States Court of Appeals for the District of Columbia.